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Cash In & Cash Out Added For CTR?

Question: 
Based on 31 CFR 103.22(c)(2), multiple currency transactions shall be treated as a single transaction if the bank has knowledge and result in either cash in or cash out totaling more than $10,000 during any one business day. Does this mean that if Customer A deposits (cash in) $9,000.00 in cash and cashes (cash out) a check for $1,500.00 on the same day, the single transaction totals $10,500 and therefore, a CTR is required?
Answer: 

Answer by Jim Bedsole:

No, cash ins would be aggregated with other cash ins and cash outs with other cash outs, but cash ins are neither aggregated with cash outs nor are they netted against cash outs.

In your example, no CTR would be required because there weren't aggregate cash ins in excess of $10K, nor were there aggregate cash outs in excess of $10K.

Another example Customer A deposits $11,000 in cash (cash in). Later that same day, customer A cashes a check for $2,000 (cash out). You cannot net the $2,000 out against the $11,000 in for a net cash transaction of $9,000 and say no CTR is required. A CTR would be required for the $11,000 cash in, regardless of what cash out activity takes place.

Answer: 

Answer by Richard Insley:

Read the instructions on Page 4 of the CTR form.

Answer: 

Answer by Barbara McGuire:

No. The "cashins" and "cashouts" are apples and oranges...You would not add them together to reach a total. The bank would need that $1,500 to be a cashIN (not OUT) in order to be able to add it to the $9000 already collected to determine if a CTR is required.

First published on BankersOnline.com 08/18/03

First published on 08/18/2003

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